Has there been any notable court cases involving injunctive relief prior to perdomo v. noem?

1. Lyons: the enduring precedent on standing for injunctive relief

The landmark case Los Angeles v. Lyons continues to be the touchstone when courts ask whether a plaintiff who suffered past harm can seek an injunction against future government conduct, with the Supreme Court in Lyons holding that a speculative fear of recurrence does not satisfy Article III’s “real and immediate” threat requirement—an analysis the government and several justices invoked repeatedly in Noem v. Vasquez Perdomo ^{[2] [1] [5]}.

2. Recent Supreme Court decisions that reshaped injunction doctrine before Perdomo

In the years before Perdomo reached the high court, the Court’s emergency and merits rulings—cited in Noem v. Vasquez Perdomo—already narrowed equitable relief in immigration and executive‑action contexts, notably decisions and commentary referencing Trump v. CASA and state‑challenge cases such as United States v. Texas and Biden v. Texas, which the Perdomo opinions used to frame limits on courts’ equitable powers and on nationwide injunctions ^{[4] [6] [7]}.

3. The district‑court practice and TROs that set the immediate stage

The Perdomo litigation itself grew from conventional injunctive practice at the district level: on July 11, 2025 Judge Frimpong granted temporary restraining orders blocking certain ICE stops and requiring access to counsel—classic uses of interim equitable relief that plaintiffs sought to convert into a longer preliminary injunction, a procedural path courts regularly use before resolving merits ^{[3] [8]}.

4. Ninth Circuit and Supreme Court interplay on standing and scope

The Ninth Circuit’s treatment of standing and a “pattern of officially sanctioned behavior” supplied a counterweight to Lyons when it found plaintiffs faced a realistic threat of future stops and thus could seek injunctive relief, a factual‑record‑intensive posture the Supreme Court’s emergency stay later questioned on Article III and equitable grounds ^{[9] [1] [2]}.

5. Competing views: textual limits vs. equitable tailoring

Scholars and dissenting justices have emphasized that Lyons should not categorically foreclose injunctive relief where an ongoing, systemwide practice is documented—Justice Sotomayor’s dissent in the Perdomo stay argued the district court’s record of racially‑tainted stops justified prospective relief, while the majority leaned on Lyons and other precedents to stress Article III and restraint in equity ^{[10] [5] [11]}.

6. What counts as “notable” cases before Perdomo

If “notable” means Supreme Court decisions that directly shaped injunctive‑relief doctrine, Los Angeles v. Lyons is the principal antecedent cited throughout the Perdomo materials, and more recent high‑profile shadow‑docket orders and merits decisions like Trump v. CASA and the Court’s stays of district orders fed into Perdomo’s legal framing; if “notable” includes influential interlocutory rulings at the circuit or district level, the July 2025 TROs and Ninth Circuit rulings in Vasquez Perdomo itself were pivotal within the litigation’s procedural history ^{[1] [2] [4] [3] [9]}.

7. Limits of the reporting and open questions

The sourced reporting chronicles Lyons and the cascade of 2024–2025 injunction jurisprudence and documents the TROs and appeals in the Vasquez Perdomo docket, but these materials do not exhaustively catalog every injunctive decision nationwide prior to Perdomo—therefore, while Lyons and Trump v. CASA emerge as the most influential Supreme Court touchstones cited by the parties and the Court, a comprehensive empirical list of all notable injunctive rulings before Perdomo is beyond the provided sources ^{[2] [4] [7]}.